K Number
K051471
Device Name
CARDIODAY
Date Cleared
2005-06-29

(26 days)

Product Code
Regulation Number
870.1425
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
CardioDay" is a software package that allows a trained physician or health care professional knowledgeable in Holter interpretation, after having performed a long-term continuous electrocardiographic (ECG) recording on digital flash memory Holter recorder, to download and analyze the data from the recorder, review it and produce printed reports. This device is available only upon the order of a physician or other licensed medical professional and not intended for any ambulatory or home applications. Federal law restricts CardioDay® to use on order of a physician. CardioDay is a Holter software which is indicated for patients who may benefit from a long-term continuous electrocardiographic (ECG) recording, but not limited to, those with complaints of palpitations, syncope, chest pain, shortness of breath, or those that need to be monitored to judge their current cardiac functionality such as patients who have recently received pacemakers. WARNING: CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values.
Device Description
CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values in graphical form. The physician will be able to review, edit, and print the data collected. CardioDay® is a software package which is delivered on CD.
More Information

Not Found

No
The document explicitly states that the device "does not perform any diagnosis of data by itself" and only displays calculated values and graphs. There is no mention of AI, ML, or related terms in the description or the "Mentions AI, DNN, or ML" section.

No
The device is a software package for data analysis and reporting from Holter recordings, not for direct treatment or therapy. It displays ECG morphologies and calculated graphs for physician review, but does not perform diagnosis or therapeutic functions itself.

No
The device is described as a software package that allows a physician to download, analyze, review, and produce reports from long-term continuous ECG recordings. However, the text explicitly states, "CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs." This indicates it is a tool for data presentation and analysis, not a diagnostic device that renders a diagnosis.

Yes

The device is described as a "software package" delivered on a CD, and its function is to download, analyze, review, and produce reports from data collected by a separate digital flash memory Holter recorder. It does not include the hardware recorder itself.

Based on the provided information, this device is NOT an In Vitro Diagnostic (IVD).

Here's why:

  • IVDs are used to examine specimens derived from the human body. The intended use and device description clearly state that CardioDay® analyzes electrocardiographic (ECG) recordings, which are electrical signals measured from the body's surface, not specimens like blood, urine, or tissue.
  • The device processes electrical signals, not biological samples. The input modality is ECG recording, which is a measurement of electrical activity, not a biological sample.
  • The device's function is to display and analyze ECG data. It does not perform tests on biological specimens to diagnose diseases or conditions.

The device is a software package for analyzing physiological data (ECG) collected from a patient, which falls under the category of medical devices, but not specifically In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

CardioDay" is a software package that allows a trained physician or health care professional knowledgeable in Holter interpretation, after having performed a long-term continuous electrocardiographic (ECG) recording on digital flash memory Holter recorder, to download and analyze the data from the recorder, review it and produce printed reports.

This device is available only upon the order of a physician or other licensed medical professional and not intended for any ambulatory or home applications.

Federal law restricts CardioDay® to use on order of a physician.

CardioDay is a Holter software which is indicated for patients who may benefit from a long-term continuous electrocardiographic (ECG) recording, but not limited to, those with complaints of palpitations, syncope, chest pain, shortness of breath, or those that need to be monitored to judge their current cardiac functionality such as patients who have recently received pacemakers.

WARNING:
CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values.

Product codes

DQK

Device Description

CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values in graphical form. The physician will be able to review, edit, and print the data collected.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

trained physician or health care professional knowledgeable in Holter interpretation / Not intended for any ambulatory or home applications.

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The impact of all parameters, especially those specified above, is evaluated with the help of the data bases from American Heart Association (AHA) and Massachusetts Institute of Technology (MIT) and performance evaluations.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K930564

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.1425 Programmable diagnostic computer.

(a)
Identification. A programmable diagnostic computer is a device that can be programmed to compute various physiologic or blood flow parameters based on the output from one or more electrodes, transducers, or measuring devices; this device includes any associated commercially supplied programs.(b)
Classification. Class II (performance standards).

0

JUN 29 2005

510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D

1 510(k) - Summary

| Submitted By: | getemed Medizin- und Informationstechnik AG
Oderstr. 59
14513 Teltow
Germany
Tel.: +49 3328 - 3942-70
Fax: +49 3328 - 3942-99 |
|---------------------------|----------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Dr. Bert Schadow
Regulatory Affairs Manager |
| Manufacturing Facility: | getemed Medizin- und Informationstechnik AG
Oderstr. 59
14513 Teltow
Germany |
| Date of Preparation: | 2005-06-13 |
| Trade Name: | CardioDay® |
| Common Name: | Holter ECG |
| Classification Name: | Computer, Diagnostic, Programmable |
| Product Classification: | 21 CFR 870.1425, Class II |
| Product Code: | DQK |
| Legally Marketed Devices: | Holter for Windows® (K930564, Northeast
Monitoring Inc.) |

Reason for Submission

Premarket notification for CardioDay® (Version 1.9.5), a New Device, seeking authority to market the device under Section 510(k) as a device that is substantially equivalent to the Holter for Windows® evaluation software (K930564, Northeast Monitoring Inc.).

Intended Use

CardioDay" is a software package that allows a trained physician or health care professional knowledgeable in Holter interpretation, after having performed a long-term continuous electrocardiographic (ECG) recording on digital flash memory Holter recorder, to download and analyze the data from the recorder, review it and produce printed reports.

This device is available only upon the order of a physician or other licensed medical professional and not intended for any ambulatory or home applications.

Federal law restricts CardioDay® to use on order of a physician.

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc CONFIDENTIAL AND PROPRIETARY

1

510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D

Indications for Use

CardioDay is a Holter software which is indicated for patients who may benefit from a long-term continuous electrocardiographic (ECG) recording, but not limited to, those with complaints of palpitations, syncope, chest pain, shortness of breath, or those that need to be monitored to judge their current cardiac functionality such as patients who have recently received pacemakers.

WARNING:

CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values.

Device Description

CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values in graphical form. The physician will be able to review, edit, and print the data collected.

Description
Intended useHolter for Windows® is Holter
monitoring software, designed to
perform high-speed data analysis
of continuous, long-term
electrocardiograms saved in the
form of direct recordings on a
cassette tape or flash memory
card. Holter for Windows® is
intended for use as an analysis
tool and produces printed reports
to be reviewed by a person
knowledgeable in Holter
interpretation.

Federal law restricts Holter for
Windows® to use on order of a
physician. | CardioDay® is a software package
that allows a trained physician or
health care professional
knowledgeable in Holter
interpretation, after having
performed a long-term continuous
electrocardiographic (ECG)
recording on digital flash memory
Holter recorder, to download and
analyze the data from the recorder,
review it and produce printed
reports.

This device is available only upon
the order of a physician or other
licensed medical professional and
not intended for any ambulatory or
home applications.

Federal law restricts CardioDay® to
use on order of a physician. |

Comparison to Legally Marketed Device

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc CONFIDENTIAL AND PROPRIETARY

Page 2 of 11

2

510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
DescriptionFacility's CardioDay®
Predicate Index
Indications for useSame as CardioDay®CardioDay® is a Holter software
which is indicated for patients who
may benefit from a long-term
continuous electrocardiographic
(ECG) recording, including, but not
limited to, those with complaints of
palpitations, syncope, chest pain,
shortness of breath, or those that
need to be monitored to judge their
current cardiac functionality such as
patients who have recently received
pacemakers.

WARNING:
CardioDay® does not perform any
diagnosis of data by itself but only
displays ECG morphologies and
associated, calculated graphs such
as heart rate trends, RR variability,
and other statistical values. | |
| Device description | Same as CardioDay® | CardioDay® does not perform any
diagnosis of data by itself but only
displays ECG morphologies and
associated, calculated graphs such
as heart rate trends, RR variability,
and other statistical values in
graphical form. The physician will be
able to review, edit, and print the
data collected. | |
| Target population | Same as CardioDay® | Patients who may benefit from a
long-term continuous
electrocardiographic (ECG)
recording, including, but not limited
to, those with complaints of
palpitations, syncope, chest pain,
shortness of breath, or those that
need to be monitored to judge their
current cardiac functionality such as
patients who have recently received
pacemakers. | |
| Design / materials | Same as CardioDay® | CardioDay® is a software package
which is delivered on CD. | |
| Sterility | This section does not apply. | This section does not apply. | |
| Biocompatibility | This section does not apply. | This section does not apply. | |
| Mechanical safety | This section does not apply. | This section does not apply. | |
| Chemical safety | This section does not apply. | This section does not apply. | |
| Anatomical sites | This section does not apply. | This section does not apply. | |

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc
CONFIDENTIAL AND PROPRIETARY

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ાં ડા

3

510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
DescriptionHolter for Windows®
Human factorsSame as CardioDay®Human factors engineering:
  • device technology (see
    comparison of technology
    characteristics),
  • the users (see target
    population),
  • environment in which the
    technology will be used (see
    intended use),
  • how dangerous is the use of the
    device (see level of concern in
    section 2),
  • how critical is the device for
    patient care (see product
    classification and level of
    concern in section 2). |
    | Energy used and/or
    delivered | This section does not apply. | This section does not apply. |
    | Compatibility with
    environment and
    other devices | See comparison of technology
    characteristics and miscellaneous | See comparison of technology
    characteristics and miscellaneous |
    | Where used:
    hospital, home,
    ambulance, etc. | Holter for Windows® is available
    for sale only upon the order of a
    physician or other related licensed
    medical professional. | CardioDay® is available for sale only
    upon the order of a physician or
    other related licensed medical
    professional and not intended for
    any home use applications. |
    | Electrical safety | This section does not apply. | This section does not apply. |
    | Thermal safety | This section does not apply. | This section does not apply. |
    | Radiation safety | This section does not apply. | This section does not apply. |

Comparison of Technology Characteristics Compared to Legally Marketed Device:

Specifications
TypeIBM PC AT compatibleIBM PC AT compatible
CPUPentium II ProcessorPentium III, 500MHz or greater
RAM32 Mbytes minimum128 Mbytes minimum,
256 Mbytes minimum for XP
Free hard disk
space200 MB minimum5 GB minimum
20 GB for 12-lead recordings
DisplayVGA, 14", 1024 x 768 pixel, 256
colors17" CRT or 15" TFT, 1024 x 768
pixel (XGA), 256 colors
Disc drive / floppy
drive1.4 MbytesNot required

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc
CONFIDENTIAL AND PROPRIETARY

.

4

| 510(k) Notification

CardioDay®o getemed
Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
SpecificationsHotter for Win
CD-ROM driveFor installation onlyFor installation only.
Needs to be replaced by a CD-ROM
writer or DVD writer if archive option
implemented
Operating systemWindows 98Windows 98 SE, NT (SP6a), 2000
or XP
PortsOne free parallel port1 parallel port sufficient; if USB
devices used for printing, software
key or card reader, then
corresponding USB ports required
PrinterPrinter as any Windows ™
compatiblePrinter as any Windows ™
compatible, 300 dpi
KeyboardStandard deviceStandard device
MouseStandard, 2-button deviceStandard, 2 or 3-button device
Installation media(1) CD(1) CD
Further peripheryCompact Flash card readerCompactFlash (Type I) memory
card reader

Comparison of Software Characteristics:

| Patient Screen | FORM DESIGNATION
Section Windows | |
|-------------------------------------------------------------|-------------------------------------|-----|
| Patient Identification Number | Yes | Yes |
| Patient Name, Address, Telephone | Yes | Yes |
| Patient Personal Data (Age, Gender, Date of Birth,
etc.) | Yes | Yes |
| Medication | Yes | Yes |
| Indication | Yes | Yes |
| Physician's Name | Yes | Yes |
| Date of Recording | Yes | Yes |

Analysis Options
Analysis DurationYesYes
Primary Channel SelectionYesYes
Sensitivity / Signal QualityYesYes
Tachycardia Threshold [bpm]YesYes
Bradycardia Threshold [bpm]YesYes
Pause Duration [ms]YesYes
SV Prematurity [%]YesYes
V Prematurity [%]YesYes
R on T [ms]YesYes
Pacemaker TypeYesYes
Minimum Pulse Rate [bpm]YesYes
Maximum Pulse Rate [bpm]YesYes
Superimposition / QuickScanYesYes

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc
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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
Analysis OptionsHolter for WindowsNew Device
CardioDay
12-Lead ECG ModuleYesYes
Holter Data TransferYesYes
Events DetectedHolter for WindowsNew Device
CardioDay
BurstYesYes
VES / VPB (Extrasystole)YesYes
SVES / SVPB (Supraventricular Extrasystole)YesYes
Couplet / VPB PairYesYes
TripletYesYes
VTACH / VTAC (Ventricular Tachycardia)YesYes
BigeminyYesYes
R on TYesYes
ST-AnalysisYesYes
SVTACH / SVT (Supraventricular Tachycardia)YesYes
Arrhythmia / Irregular R-RYesYes
BradycardiaYesYes
VTACH (with 4 Beats) / BurstYesYes
V. STIM / V. PacedYesYes
A. STIM / A. PacedYesYes
AV. STIM / AV PacedYesYes
Undersense / Sense FailureYesYes
Exitblock / Capture FailureYesYes
Oversense / InhibitionYesYes
Pause / ArrestYesYes
Event MarkerYesYes
HR StripesYesYes
ArtifactYesYes
NormalYesYes
Functionality Available
The comparison between the legally marketed de-
vice and the NEW DEVICE is based on their func-
tions only and not on their names.
StartYesYes
Read TapeYesYes
Read Digital RecorderYesYes
ImportYesYes
Analyze NewYesYes
OpenYesYes
Edit Patient DataYesYes
Print PreviewYesYes
PrintYesYes
Close RecordingYesYes
CloseYesYes

0429S1-Sec01-0001-RevD-CardioDay-Execulive_Summary.doc
CONFIDENTIAL AND PROPRIETARY

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510(k) Notificationo getemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
Functionality AvailableLegally Marketed Device
Holter for WindowsPredicate Device
CardioDay
Delete RecordingYesYes
ArchiveYesYes
DiagnosisYesYes
View ECGYesYes
Print PreviewYesYes
Screen Scale CalibrationYesYes
Screen: Colour SetupYesYes
FFT SetupYesYes
Report SetupYesYes
Classes DisplayYesYes
PM Events DisplayYesYes
Events DisplayYesYes
HR Min./Max. DisplayYesYes
Statistics DisplayYesYes
Diagnosis DisplayYesYes
Overview DisplayYesYes
Context sensitive HelpYesYes
Keyboard Shortcuts HelpYesYes
Menu Entries HelpYesYes
Help: AboutYesYes
Help: VersionYesYes
Icons/Buttons AvailableLegally Marketed Device (Hotar or Window)NEW DEVICE (Display)
The following comparison between the legally
marketed device and the NEW DEVICE is based on
their functions only. The label and form of the icons
/ buttons, however, are different. It might even take
more than one click to initiate a given action.
Start: Read Digital RecorderYesYes
Start: Read Tape RecorderYesYes
Start: Open Existing RecordYesYes
Digital RecorderYesYes
Tape RecorderYesYes
Open: List of PatientsYesYes
PrintYesYes
Rhythm AnalysisYesYes
Print Preview on ScreenYesYes
Options AvailableLegally Marketed Device (Note on Wind)New Device (Note on Wind)
The following comparison between the legally mar-
keted device and the NEW DEVICE is based on their
functions only. The name of those options may vary.
ClassesYesYes
EventsYesYes
Heart Rate Min/MaxYesYes

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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
Options AvailableLegally Marketed Device Holter for WindowsNew Device CardioDay
Average Heart RateYesYes
Statistics: FFT AnalysisYesYes
Statistics: ST DiagramsYesYes
ReportYesYes
OverviewYesYes
Heart Variability: RR DelayYesYes
Heart Rate Variability: RR FFTYesYes
Heart Rate Variability: 24h RR FFTYesYes
Heart Rate Variability: RR HistogramsYesYes
Graphics & Displays AvailableLegally Marketed Device:
Holter for WindowsNew Device:
CardioDay
The following comparison between the legally mar-
keted device and the NEW DEVICE is based on their
functions only. The label and appearance of those
displays may vary.
Classified Beats Grouped into Morphology BinsYesYes
Zoomed Version of Selected BeatYesYes
Context of Selected BeatYesYes
EventsYesYes
Heart Rate Trend in Recording PeriodYesYes
Average RR IntervalYesYes
Y-T DistributionYesYes
RR > 50ms DistributionYesYes
FFT AnalysisYesYes
ST DiagramsYesYes
Overview 2 channels at Different Scaling FactorsYesYes
Printout OptionsLegally Marketed Device
Hoferator WindowNew Device
CardioDay
The following comparison between the legally mar-
keted device and the NEW DEVICE is based on their
functionality only. The commands to generate a
given printout as well as its appearance do vary.
Full Disclosure 2 Channels, 1 h/PageYesYes
Full Disclosure 2 Channels, 15 min./PageNoYes
Full Disclosure 2 Channels, 30 min./PageYesYes
Marked Events: 8 Events/PageYesYes
Marked Events: 32 Events/PageYesYes
Marked Events: Analysis Channel 25 mm/sYesYes
Marked Events: Analysis Channel 2.5 min +
25mm/sNoYes
Selected Channels 25 mm/sYesYes
Selected Channels 1 min. + 25 mm/sYesYes
Selected Channels 2.5 min. + 25 mm/sNoYes
Selected Channels 10 min. + 25 mm/sNoYes
Event TableYesYes

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc
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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
Printout OptionsLegally Marketed Device Holter for WindowNew Device CardioDay
Event HistogramYesYes
Heart Rate and ST DiagramsYesYes
HR diagram + Min/Max per MinuteNoYes
RR IntervalsYesYes
RR DelayNoYes
RR HistogramsNoYes
RR Interval SpectraNoYes
Pacemaker Event HistogramYesYes
Pacemaker Function AnalysisYesYes
ReportYesYes
Print to File (PDF)YesYes
Save as Default OptionYesYes
Editing & Reviewing OptionsLegally Marketed Device to WindowsNew Device CardioDay
The following comparison between the legally mar- keted device and the NEW DEVICE is based on their functions only. The label and appearance of those options may vary.
Scroll through all Beats in a Morphology BinYesYes
Edit all Beat Labels in a Morphology BinNoYes
Scroll through ECG and Edit Single Beat LabelsNoYes
Scroll through Events of the Same TypeYesYes
Edit Event MarkerYesYes
View Patient Event MarkersYesYes
Jump from any Statistics Diagram to the corresponding ECGNoYes
Jump from ECG Overview to the corresponding ECGYesYes
Select Tme Interval for Time Domain RR ParametersYesYes
Edit ReportYesYes
MiscellaneousLegally Marketed Device Holter for WindowsNew Device Cardiology
RZ153+ Digital Recorder Supported (K022540)YesYes
CardioMem® CM 3000 (SMA) SupportedYesYes
CardioMem® CM 3000-12 SupportedNoYes
CD Installation MediumYesYes
RZ151 Analog Recorder SupportedNoNo
CD Installation MediumYesYes

Standards Comparison

| Standard | Device Master Record
Device History Record | CardioDay |
|------------------------------------------------------|-----------------------------------------------|-----------|
| 21 CFR 820 (FDA cGMP Good Manufacturing
Practice) | Yes | Yes |

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510(k) Notificationo getemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
StandardComply Marked Device
Holter for WindowsNon-Device (C-Code Only)
ISO 9001:2000 / EN 46001 / ISO 13485:2003
Quality Management SystemsYesYes
IEC 60601-1-4 + A1 Programmable Electrical
Medical SystemsYesYes
ANSI/AAMI EC38 Ambulatory ElectrocardiographsYesYes
IEC 60601-2-47 Particular Requirements for the
Safety, including Essential Performance, of
Ambulatory Electrocardiographic SystemsYesYes
ISO 14971 +A1 Application of the Risk
Management to Medical DevicesYesYes
EN 980 Graphic Symbols for the Marking of
Medical DevicesYesYes
EN 1041 Supply of Information by the Manufacturer
of a Medical DeviceYesYes
ISO 15223 + AMD1 + AMD2 Symbols to be Used
with Medical DevicesYesYes

Differences between the Legally Marketed Device (Holter for Windows®) and the New Device (CardioDay®):

Where Used: Hospital, Home, Ambulance, etc.:

CardioDay® clearly excludes home use applications. This has no influence on safety and effectiveness.

Performance

CardioDay and Holter for Windows® have the following different technology specifications:

| Specifications | Legally Marketed Device
Hot for Windows | New Device
OrtotoBay |
|---------------------------|--------------------------------------------|---------------------------------------------------------------------------------------------------------------------|
| CPU | Pentium II Processor | Pentium III, 500MHz or greater |
| RAM | 32 Mbytes minimum | 128 Mbytes minimum,
256 Mbytes minimum for XP |
| Free hard disk space | 200 MB minimum | 5 GB minimum
20 GB for 12-lead recordings |
| Display | VGA, 14", 1024 x 768 pixel,
256 colors | 17" CRT or 15" TFT, 1024 x 768 pixel
(XGA), 256 colors |
| Disc drive / floppy drive | 1.4 Mbytes | Not required |
| CD-ROM drive | For installation only | For installation only.
Needs to be replaced by a CD-ROM
writer or DVD writer if archive option
implemented |
| Operating system | Windows 98 | Windows 98 SE, NT (SP6a), 2000 or XP |

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K051471/SI
$\frac{11}{11}$

510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
PortsOne free parallel port1 parallel port sufficient; if USB devices
used for printing, software key or card
reader, then corresponding USB ports
required

The minimum hardware requirements, such as CPU, RAM, free Hard disk space, display, CD-ROM drive and ports and supported operating system of CardioDay® correspond to the current state of the art. No influence on safety and effectiveness is expected.

Software characteristics

The new device CardioDay offers a number of editing and printing options not available in the legally marketed device. No influence on safety and effectiveness is expected.

Miscellaneous

Holter for Windows® does not support the Holter recorder CardioMem® CM 3000-12. No influence on safety and effectiveness is expected.

CardioDay® does not support the RZ 151 analog tape recorder. This technology is no longer state of the art and therefore it is not supported. No influence on safety and effectiveness is expected.

Conclusion

CardioDay and Holter for Windows® software packages are both used in clinical applications to allow trained physicians or other health care providers to download, review and print electrocardiographic (ECG) data recorded on digital Holter recorders. Both are computerized programs which run under a computer operating system. Both perform a high-speed analysis of the recorded ECG data and use the computer operating system to access the displayed data. CardioDay® has the same analysis modes as Holter for Windows®. The impact of all parameters, especially those specified above, is evaluated with the help of the data bases from American Heart Association (AHA) and Massachusetts Institute of Technology (MIT) and performance evaluations.

WARNING:

CardioDay' does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends. RR variability, and other statistical values.

CardioDay conforms to Good Manufacturing Procedures outlined by the FDA GMP. This software is safe and effective for the application for which it is intended and has been tested to confirm the safety and efficacy of the software. CardioDay® is found to be substantially equivalent to the Holter for Windows® software.

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc CONFIDENTIAL AND PROPRIETARY

11

Image /page/11/Picture/1 description: The image shows the seal of the U.S. Department of Health and Human Services. The seal features a stylized eagle with three lines representing its wings and body. The eagle is encircled by the text "DEPARTMENT OF HEALTH AND HUMAN SERVICES, U.S.A."

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

JUN 2 9 2005

getemed Medizin-und Informationstechnik AG c/o Mr. Tamas Borsai Division Manager, Medical Division TUV Rheinland of North America 12 Commerce Road Newtown, CT 06470

Re: K051471 Trade Name: CardioDay® Regulation Number: 21 CFR 870.1425 Regulation Name: Diagnostic Programmable Computer Regulatory Class: Class II (two) Product Code: DOK Dated: June 16, 2005 Received: June 17, 2005

Dear Mr. Borsai:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

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Page 2 - Mr. Tamas Borsai

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0295_ Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours.

Blummer for
R. D. Zuber, M.D.

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known):

CardioDay® Device Name:

Indications For Use:

CardioDay® is a Holter Software which is indicated for patients who may benefit from a long-term continuous electrocardiographic (ECG) recording, including, but not limited to, those with complaints of palpitations, syncope, chest pain, shortness of breath, or those that need to be monitored to judge their current cardiac functionality such as patients who have recently received pacemakers.

WARNING:

CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values.

Prescription Use (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use _ (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Blommima

(Division Sign-Off) Division of Cardiovascular Devices 510(k) Number

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